In Poland, you can run a small business without registering a company or a sole proprietorship: this is called działalność nierejestrowana (unregistered business activity). Here’s the current revenue limit for 2026, who is eligible, what obligations it carries, and why it’s not a good fit for an ongoing B2B contract with a single client.

What is działalność nierejestrowana and what’s the 2026 limit

In force since April 2018 (Art. 5 of the Entrepreneurs’ Law), this form lets an individual earn money without registering a company, as long as revenue stays under the statutory limit. Note that the limit applies to revenue (amounts received from clients), not income (revenue minus costs).

As of January 1, 2026, the limit rule changed: it’s now calculated per quarter rather than per month. The limit is 225% of the minimum wage per quarter. At the 2026 minimum wage of 4,806 zł gross, that’s 10,813.50 zł per quarter, mathematically the same average of 3,604.50 zł a month, but with more flexibility: you can earn more in one month and less in another, as long as the quarterly total stays under the limit.

History of the limit: before July 1, 2023, the limit was 50% of the minimum wage per month; from July 1, 2023 (the act of January 26, 2023 on eliminating unnecessary administrative and legal barriers, Journal of Laws 2023, item 803, Art. 14), it was raised to 75% of the minimum wage per month; from January 1, 2026, the rule became quarterly (225% of the minimum wage per quarter, the same monthly average mathematically, but assessed over three months).

If your turnover exceeds the limit, you have 7 days to register your business with CEIDG.

Who can run an unregistered business

You can run an unregistered business if you meet all of the following conditions:

  • you operate solely as a private individual;
  • you don’t operate within a spółka cywilna (civil-law partnership);
  • the activity doesn’t require any additional permit or license under the law;
  • you haven’t run a registered business activity at any point during the 60 months preceding the start of this activity.

Unregistered business for foreigners

Foreigners in Poland also have the right to run an unregistered business, but there are nuances tied to civil-law contracts.

If your unregistered activity involves signing a civil-law contract to sell a product or service (for example, a written agreement with a specific buyer), you generally need a permit from the voivode. Exempt from this requirement are people who are legally entitled to register a sole proprietorship (JDG) in Poland: for example, EU citizens, holders of a permanent residence permit, EU long-term resident status, a valid Pole’s Card, refugee status, and several other categories.

PeriodRule for foreigners
Until 1 June 2025Legal residence in Poland was generally sufficient to run unregistered activity
From 1 June 2025A specific residence basis that explicitly allows conducting business activity in Poland is required, legal residence alone (e.g. on a visa without the right to run a business) is no longer enough

This is a key change to check before starting: merely having legal residence no longer guarantees the right to conduct unregistered activity. If your residence basis doesn’t allow business activity in Poland, such activity may be deemed illegal, which risks both tax and residence-status consequences.

Ukrainian citizens with temporary-protection status (PESEL UKR) don’t need this permit, they belong to the category of people entitled to register a JDG on equal terms with Polish citizens (see the current status in Ukraine Special Act 2026: What Changed). The full list of categories exempt from this requirement is covered in Business Incubator vs. Sole Proprietorship: Pros and Cons.

If the transaction doesn’t involve a contract at all: for example, you sold a product directly to a buyer without a written agreement, without exceeding the revenue limit, no permit from the voivode is needed in the first place.

Obligations of an unregistered business

Despite the simplified process, you can’t fully avoid reporting obligations. Działalność nierejestrowana requires you to:

  • keep a simplified sales log (a register with a sequence number, sale date, price of the goods or service, and total income);
  • report income from the unregistered activity (after deducting costs) in your annual PIT-36 tax return, taxed under the ordinary tax scale (12%/32%);
  • comply with consumer-protection rules, including the buyer’s right to return goods within 14 days;
  • issue a bill or invoice on the buyer’s request.

Record-keeping, PIT-36, and switching to a JDG

You don’t pay advance tax installments: the tax is settled once a year, based on your PIT-36 return, which has a dedicated section for działalność nierejestrowana. Documented expenses can be deducted from revenue to reduce your taxable base.

Once your revenue exceeds the limit, you have 7 days to register a sole proprietorship (JDG) in CEIDG, for free, and usually the same day.

Health insurance and ZUS

Unregistered activity isn’t subject to mandatory ZUS contributions or the health insurance contribution tied to running a business, since formally it isn’t a business activity under the Entrepreneurs’ Law. This is one of the main advantages of this format compared to a JDG, where even at low income levels you have to pay the health contribution and, after a relief period, social contributions.

A person running unregistered activity still needs some other basis for health insurance: for example an employment contract with another employer, insurance as a family member, student status registered for insurance by a university, or voluntary health insurance with the NFZ paid independently. Without any of these titles, you have no access to public healthcare financed by the NFZ.

If a civil-law contract concluded within unregistered activity has the character of a mandate contract (umowa zlecenia), the client may be obligated to pay ZUS contributions for that contract, just as with a regular mandate contract with an individual. This depends on the specific structure of the cooperation, so it’s worth clarifying with an accountant before signing.

How to start unregistered activity step by step

Unlike a JDG, starting unregistered activity doesn’t require any registration with CEIDG or notifying the tax office before the first sale. Still, it’s worth handling a few formalities from the start:

  • check whether the planned activity even qualifies for this format (no requirement for a concession, license, or entry in a register of regulated activities);
  • for foreigners, verify whether your residence basis allows conducting business activity in Poland (the legal state after 1 June 2025);
  • set up simple sales records (even a plain spreadsheet with a date, transaction description, and amount) to track the quarterly revenue limit;
  • determine whether you need to issue receipts or invoices (mandatory on the customer’s request, regardless of whether it’s a consumer or a business);
  • check whether the planned sale requires an online cash register from day one (this applies e.g. to some hairdressing, cosmetic, or catering services, regardless of the turnover limit);
  • open a separate bank account, or at least keep a separate tab in a private account, to make it easier to settle income at year’s end.

If revenue starts approaching the quarterly limit during the year, it’s worth preparing in advance for a JDG registration, to avoid having to do it in a rush within 7 days of exceeding the threshold.

Is this suitable for a B2B contract with a single client

Generally, no. Działalność nierejestrowana was designed for one-off or irregular transactions by first-time entrepreneurs, not as a substitute for a JDG in an ongoing relationship with a single counterparty. There are two reasons for this.

First, the revenue limit (10,813.50 zł per quarter in 2026) is too low for a full IT or consulting B2B contract: most such contracts exceed it within the first month.

Second, even if you do manage to stay under the limit, working regularly and continuously for the same client on a pre-agreed schedule is, by itself, a red flag under the 2026 PIP reform. Since July 8, 2026, National Labour Inspectorate inspectors can independently establish that a de facto employment relationship exists even where there’s formally no JDG or registered activity at all, if the work is performed under the client’s direction, at a place and time it sets. Regularity and scale of cooperation with a single counterparty is one of the key markers of disguised employment, regardless of whether the activity is structured as an unregistered business, a JDG, or through an incubator. For more, see our series on the 2026 PIP reform here.

FAQ

Do I need to open a business bank account for an unregistered business?
No, a separate account isn’t required, but it’s a good idea to keep at least a simple log of incoming payments, on a separate page or file, to track the limit.

What happens if I exceed the limit once and then earn less again?
Since 2026, the limit is assessed for the whole quarter rather than separately for each month, so a single high-earning month isn’t critical as long as the quarterly total (10,813.50 zł) isn’t exceeded. But once you exceed the quarterly limit, you have 7 days to register a JDG.

Can I run an unregistered business alongside a regular job?
Yes, this is allowed: an unregistered business isn’t tied to your main source of income.

Can I issue VAT invoices with unregistered activity?
Yes, if you use the VAT exemption (standard at such low turnover), you issue receipts or invoices without VAT. Registering as an active VAT payer is possible but rarely worthwhile at these revenue limits.

Does unregistered activity count towards seniority when applying for a residence permit?
No, it isn’t a business activity under the law, so it doesn’t build entrepreneur seniority the way a registered JDG does. In the context of legalizing residence, it’s worth consulting individually with a lawyer.

Bibliography and Legal Basis

Author: the Moja Firma team.

This article is for informational purposes only and does not constitute legal advice. Every situation depends on the specific facts and circumstances. If anything about your own case isn’t quite clear, feel free to book a free consultation with our team.